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The latest analysis of suspension and debarment by Donald Robbins of Jenner & Black for Law360 shows that USAID suspends individuals much more frequently than firms or organizations. In the recently concluded FY2024, USAID suspended or debarred 15 individuals and no firms. In FY 2023, USAID suspended or debarred 23 individuals and no firms. The State Department did not suspend or debar any individuals or entities in FY 2024. The analysis has tracked a trend since 2016 of a steady decline in overall suspensions and debarment across the U.S. Government, although the rate for individuals is leveling out. Small businesses are also much more likely to be suspended or debarred than larger firms.

The steady decline may be due to greater efforts on the part of government contractors and recipients to be more ethical and compliant. It’s also possible that the cases presented are not reaching the “preponderance of evidence” standard to warrant suspension or debarment. A more likely explanation, at least for USAID, is that USAID is focusing on safeguarding cases, which would account for the number of individuals suspended or debarred.

Read the analysis at Law360 here.